Smoke seals on service ducts.

[kurnal]

Isn't there something about adapting to technical change? In this case the effect of the change in lift technology is to create a significant fire loading in a lift shaft which was historically a pretty sterile area and separated from the plant room. Worse still on the EN the benchmark is for the lift to descend to ground floor and stop with even the non FR  doors open.  In danger of going off topic but I see this as a significant risk in what should be a protected shaft and the authority having control should review and make a judgement  based on the risk to the building and not code hug what it happens to say in general guidance.

[Fishy]

The proof of the need was confirmed by the smoke spread during the fire.

With respect, the proof of the need would be if persons were put at unacceptable risk of death or serious injury resulting from the lack of smoke seals; I am not convinced this is the case from the information we have been provided.

The problem here appears not to be the lack of smoke seals on riser doors but more that the corridor was petrol bombed, or similar such event which was outside the  parameters of the Building Regs design.

A couple of comments:

I'm not quite sure why one would assume that arson is "...outside the parameters of Building Regs design"?  Our guidance to the Reg's usually assumes that you might have a fire of significant size, from whatever source - it (in my view) makes no presumption about what the initiating event might be.  The only nod that they might make to such events is that it's custom & practice not to consider the initiation of two significant fires in different places in the premises at the same time.

As regards the "unacceptable" risk... at the risk of being pedantic in England & Wales at least that isn't exactly what the legislation says.  it states that offences are caused where occupants are put... "...at risk of death or serious injury in case of fire..."..  It doesn't mention high, low, significant or unacceptable.  So far as I understand it the courts would tend to use that level of risk that would be achieved using good practice & modern standards as the benchmark - hence we generally aim to comply with that, unless we can demonstrate that they are inapplicable or inappropriate to apply to the particular situation in question, or we adopt an alternative approach that achieves the same level of fire risk by other means.   The May 2012 determination is a good example... I'm personally sure the fact that the hotel in question had smoke detectors installed in all the bedrooms (which enhances the level of safety over and above the heat detectors that would normally be installed in those locations) was a contributing factor in that determination being granted.

[Dinnertime Dave]

Whilst acknowledging the 2012 determination, there is a significant difference. The hotel will carry out simultaneous evacuation. This is a block of flats/bedsits with a delayed/stay put procedure. Based on the risk to the residents ironically caused mostly by their own lifestyle, I will be recommending that smoke seals are installed. The doors are also poor fitting so most require work.

[Jim Scott]

I have encountered this issue many times, i believe it is an error of omission in table B2

The draft BS 9999 2016 is a direct lift from table B2.

Maybe its worth raising at the consultation?

[idlefire]

The doors are also poor fitting so most require work.

Whilst I stand by my original response to your initial question (as a general principle), the fact that the doors involved are not close fitting into their frames is very significant information not included in the original question.

In light of this new information it now seems reasonable to me for the fire authority to require cold smoke seals to compensate for the lack of a natural seal between door and frame that close fitting door should afford and; recommending the fitting of such seals is a good call on your part Dave.

[Davo]

DD

Are the doors full height and kept locked?

I have known a fuse box flare and set fire to the cleaners brushes etc smoke leaking into the corridor gave it away (Handy Storage!)

regards

davo

ps to answer the question, I suggest get a quote........

[idlefire]

So far as I understand it the courts would tend to use that level of risk that would be achieved using good practice & modern standards as the benchmark - hence we generally aim to comply with that, unless we can demonstrate that they are inapplicable or inappropriate to apply to the particular situation in question, or we adopt an alternative approach that achieves the same level of fire risk by other means. 

Exactly Fishy, but the whole point is that the premises DOES comply with the standards and good practice prescribed in the current Approved Document in support of Building Regulations 2010.

My understanding is that the fire authority never suggested that an offence may have been committed under Article 32 (1) (a), merely that cold smoke seals were required under the Fire Safety Order despite not being required under Building Regulations 2010; however, the original post did fail to mention that the doors concerned were ill fitting.  

My reference to unacceptable risk is from the "Decision tree for action plan when existing premises DO NOT comply with current standards" (PAS 79:2012, p.23): "do departures from current standards create unacceptable risk?" and; along with the reference to the 2012 determination was used in that context.

With regards to my comments on the parameters of design, corridors are generally designed on the assumption that they will me managed as relatively fire sterile areas; the fact that they are not always so managed and/or an arsonist might actually introduce a fire loading (a good example would be the scrotes who set fire to tyres within single stairways of high rise residential blocks).

[Dinnertime Dave]

DD

Are the doors full height and kept locked?

I have known a fuse box flare and set fire to the cleaners brushes etc smoke leaking into the corridor gave it away (Handy Storage!)

regards

davo

ps to answer the question, I suggest get a quote........

Yes the doors are all full height and all were locked by key.

[kurnal]

Exactly Fishy, but the whole point is that the premises DOES comply with the standards and good practice prescribed in the current Approved Document in support of Building Regulations 2010.

My understanding is that the fire authority never suggested that an offence may have been committed under Article 32 (1) (a), merely that cold smoke seals were required under the Fire Safety Order despite not being required under Building Regulations 2010; however, the original post did fail to mention that the doors concerned were ill fitting.  

My reference to unacceptable risk is from the "Decision tree for action plan when existing premises DO NOT comply with current standards" (PAS 79:2012, p.23): "do departures from current standards create unacceptable risk?" and; along with the reference to the 2012 determination was used in that context.

With regards to my comments on the parameters of design, corridors are generally designed on the assumption that they will me managed as relatively fire sterile areas; the fact that they are not always so managed and/or an arsonist might actually introduce a fire loading (a good example would be the scrotes who set fire to tyres within single stairways of high rise residential blocks).

.

Thank you idlefire for a very good point clearly made. I had initially jumped to the conclusion that the absence of seals had caused the corridor smoke logging, things are rarely so simple! But the discussion has identified the issue of perspective.

There is the perspective of enforcement and I agree with your position on this and the status of national guidance in determining whether due diligence has been exercised and the use of the decision tree in this regard. The fire service has little option but to follow such guidance. Enforcement activity is only half of the picture and usually reactive and retrospective in its application.

The legislation of course requires the RP to carry out a fire risk assessment and many on this forum are employed to carry out such assessments and make recommendations based on a far wider spectrum of issues than the Building Regulations and the standards that the fire service may be able to enforce.

I would not want to see fire risk assessors limited to the strict application of legally enforceable guidance - we need to identify the right standard of fire safety for the protection of relevant persons. And it was from this perspective that my comments were based. Hopefully a competent FRA would identify the justification for this, but like my lift example the RP is likely to be told by Building Control that they don't need to do this and ignore the recommendation.

That's up to the RP  of course- they own the risk. But very often there are other weaknesses that are overlooked or not seen by the BCO

[idlefire]

The legislation of course requires the RP to carry out a fire risk assessment and many on this forum are employed to carry out such assessments and make recommendations based on a far wider spectrum of issues than the Building Regulations and the standards that the fire service may be able to enforce.

I would not want to see fire risk assessors limited to the strict application of legally enforceable guidance - we need to identify the right standard of fire safety for the protection of relevant persons. And it was from this perspective that my comments were based. Hopefully a competent FRA would identify the justification for this, but like my lift example the RP is likely to be told by Building Control that they don't need to do this and ignore the recommendation.

Whilst I agree with these comments 100% I do feel the need to add a caveat, apologies in advance if this appears a pedantic point that patronises: 

In the same way that I believe a fire authority should clearly differentiate between what is enforceable and what they are offering as "goodwill advice", so too must a competent fire risk assessor differentiate between what preventative and protective measures must be applied to comply with the Order and any additional measures that they are recommending. 

I know of many instances where this demarcation has not been clearly made in fire risk assessments and IOs have taken the opportunity to impose a much higher standard on the RP than they would otherwise have been able to enforce; citing that the RP is required by the Order to implement all the preventative and protective measures identified in their fire risk assessment.

[Davo]

Agreed idlefire, a well respected contributer here uses scores out of 20, which I gratefully adopted with permission.....

davo